Michael Kohn, et al v. CIR, No. 09-3092 (8th Cir. 2010)
Annotate this CaseCourt Description: Tax Court. Tax Court's decision upholding a Notice of Determination affirmed without comment.
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United States Court of Appeals FOR THE EIGHTH CIRCUIT ___________ No. 09-3092 ___________ Michael E. Kohn; Catherine K. Kohn, * * Appellants, * * Appeal from the United States v. * Tax Court. * Commissioner of Internal Revenue, * [UNPUBLISHED] * Appellee. * ___________ Submitted: May 2, 2010 Filed: May 26, 2010 ___________ Before WOLLMAN, COLLOTON, and GRUENDER, Circuit Judges. ___________ PER CURIAM. Michael Kohn and Catherine Kohn challenge the tax court s1 decision, rendered after a bench trial, upholding the Internal Revenue Service s Notice of Determination (NOD) related to the Kohns liabilities for tax year 2001. We review the tax court s legal conclusions de novo, and its findings of act for clear error. See Campbell v. Comm r, 164 F.3d 1140, 1142 (8th Cir. 1999). Assuming without deciding that the tax court had authority under 26 U.S.C. ยง 6330(d)(1) to consider certain matters raised by the Kohns related to tax years prior 1 The Honorable L. Paige Marvel, United States Tax Court Judge. to 2001, cf. Orum v. Comm r, 412 F.3d 819, 821-22 (7th Cir. 2005), we affirm the tax court s decision for the reasons stated in its memorandum and opinion. See 8th Cir. R. 47B. ______________________________ -2-
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